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  1. John Feldt ERPA CPC QPA
    In a small cash balance plan (a DB/DC combo design to minimize employee benefit costs), suppose that the plan's interest rate credit is written to provide for the NHCEs the greater of the 3rd segment rate under MAP21 or the 30-year treasury rate. Then, for the HCEs, it provides the lesser of the 3rd segment rate under MAP21 or the 30-year treasury rate. Perhaps define the actuarial equivalence as a fixed rate (for purposes of this discussion). Problems? The HCE benefits would grow less quickly than the NHCE benefits. Of course this helps with 401(a)(26) and 401(a)(4). Has anyone attempted this? Has anyone attempted this and received a D letter? Has anyone attempted this, been audited, and survived the audit?
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